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Compliance

Background

Anti-Money Laundering and Counter-Financing Terrorism policy

With effect from 1 November 2014, professional accountants, including public accountants will need to abide by enhanced mandatory requirements on implementing controls and procedures for anti-money laundering (AML) and countering the financing of terrorism (CFT).

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The enhanced requirements are contained in the new Ethics Pronouncement 200 - “Anti-Money Laundering and Countering the Financing of Terrorism – Requirements and Guidelines for Professional Accountants in Singapore” (PDF, 908KB) issued by the Institute of Singapore Chartered Accountants (ISCA). This pronouncement is also being adopted by the Accounting and Corporate Regulatory Authority (ACRA) and will be applicable to public accountants and accounting entities registered under the Accountants Act who are regulated by ACRA.

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Download the press release  (PDF, 364KB) for more information. To assist the accountancy profession in implementing the requirements of EP 200, ISCA has also developed the “EP 200 Implementation Guidance (IG) 1 - Frequently Asked Questions” and “IG 2 – Illustrative Customer Due Diligence Templates”. Public accountants are encouraged to refer to the IGs for guidance. The Implementation Guidance can be downloaded from ISCA’s website

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In developing the AML/CFT Guidelines for Registered Filing Agents(RFAs), feedback has been sought from RFAs as well as professional bodies including the Chartered Secretaries Institute of Singapore, Institute of Singapore Chartered Accountants, The Law Society of Singapore, Association of International Accountants (Singapore Branch) and Institute of Company Accountants Singapore. 

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The AML/CFT Guidelines for RFAs are updated from time to time to better guide RFAs in complying with prevailing regulatory requirements. The key updates to Version 2.4 of the AML/CFT Guidelines for RFAs include:

Updated the URL link for the Inter-Ministry Committee on Terrorist Designation website  

Download the Guidelines for RFAs (PDF, 796KB).

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Introduction

UPMAX is Private Limited company, a solution provider (non-financial services) support to client worldwide to incorporation company, maintain and compliance with Singapore Company Registry as well as other related authority. UPMAX committed to the highest standards in effort to comply with the applicable Anti-Money Laundering and Counter-Financing Terrorism (AML-CFT) standards. The Policy provides an introduction to anti-money laundering and counter-financing terrorism regulation.

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The management (BOD) and all employees are required to adhere the standards to protect UPMAX and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.

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Government has enacted laws and rules designed to implement the anti-money laundering and counter-financing terrorism. The goal of these laws is to detect and prevent money laundering and potential terrorist financing. UPMAX will adhere to applicable laws and regulations in Singapore.

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UPMAX will verify its AML – CFT framework, goals and strategies on an periodical basis and maintain an effective program for the UPMAX’s business that reflects the best practices for financial institution in general.

Structure and policy

UPMAX has active supervisory board under compliance officer, and the implementation of AML – CFT program handled by AML – CFT officer and all the team members (money laundering reporting officer “MLRO”) which has been appointed by the management. The MLRO is responsible for adherence to applicable AML – CFT Program derived from AML-CTF procedure.

UPMAX has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML – CFT regulations.

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The scope of this policy covers all aspects of the Implementation of Anti-Money Laundering and Counter-Financing Terrorism Prevention program, namely:

  • Active supervision of the Board of Directors

  • Policies and Procedures;

  • Internal Control;

  • Information Management System; and

  • Human Resources and Training

Client due diligence

UPMAX has implemented know your client (KYC) procedure to assure all kinds of clients are subject to identification and verification process. The KYC has been implemented in all branches and business units. The goals are UPMAX has sufficient information and data about the clients profile, whom they deals with, and also the ultimate beneficial owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and clients from high risk businessess or countries, name screening, and the ongoing monitoring and updating data of all existing clients.

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UPMAX shall refuse to support or has to close an existing clients, if the following:

  • Cannot fix a reasonable belief that it knows the true identity of the client and/or UBOs and/or the nature of business concerning the identification of the clients are not met;

  • Known and/or suspected the utilization of fake documents;

  • Assets that are known or suspected to be the proceeds of criminal activity;

  • Enter into business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or listed on sanction lists;

  • Maintain anonymous accounts or accounts operate for shell banks.

Regulatory reporting

UPMAX has an obligation to report cash transaction with certain amount based on relevant regulation, suspicious transaction/activity, and international fund transfer. Suspicious transactions must be handled and escalated with approval of compliance officer prior reporting to regulator.

AML - CFT entity risk assessment

The AML-CFT entity risk assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML-CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of terrorism financing based on client, country or geographical factors, products, services, transactions or distribution channels (delivery channels).

Sanctions compliance

Sanctions compliance implementation is important in UPMAX activities. UPMAX obligates to establish restrictions and controls on the movement of goods, services, and clients' funds were transacted through the products and services that provided by UPMAX. Sanctions compliance implementation goal is to keep UPMAX from compliance risk, operational risk and reputational risk exposure. UPMAX implements AML-CFT sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation based on UPMAX and sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.

Record retention

UPMAX has to record all data and or information regarding client's documents, client’s companies and/or its financial transactions (if any). UPMAX maintains clients documentations for minimum of 5 (five) years, notwithstanding to longer retention as required. UPMAX will provide information and/or documents competent authorities as ordered by laws and regulations, when required.

Training

UPMAX has implemented AML – CFT training program for all staff. UPMAX’s training program is tailored to the operations and business unit to assure all staffs are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML – CFT program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.

Internal control

UPMAX has an effective internal control system. UPMAX’s AML – CFT program is subject to independent control by internal audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML – CFT program.

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This policy is an integral part of UPMAX’s Anti-Money Laundering and Counter-Financing Terrorism procedure.

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